323 results for "January 2 2015"
Page 2 of 13
Giuffre_Maxwell_Batch8_p00363.png
...Was the press release that you
issued with the statement about Virginia
issued in or around January 2, 2015?
A. As best as I can recollect.
Q. I want to turn your attention to
the document I just handed you which is Bates
No. 001044, from you to Philip Barden...
Giuffre_Maxwell_Batch3_p00250.png
...at Exhibit 2).
Defendant has admitted that she again used Mr. Gow in 2015 to issue a statement relating
to Ms. Giuffre:
Q. This is an email from you on January 10, 2015 to Philip Barden and Ross Gow.
The statement you had before you earlier, that, if you can...
Giuffre_Maxwell_Batch5_p00295.png
...Friday, January 09, 2015 2:54 PM
To: Philip Barden
Cc: G Max
Subject: Re: The Times - Ghislaine Maxwell
Ghislaine
I believe the next 18hrs is the best chance we have to leverage some transparency advantage on this.
MoS first then Sunday Times. Otherwise we lose any chance of ownership...
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Case 1:15-cv-Agted? Bian dm GaonettRe porting fe Wineos/EAc.Page 83 of 89
Page 321 Page 323
1 Q_ And what do you recall any reporter saying 1 ‘Trafficking Coalition sometime after January 2nd,
2 to you that included the name Ghislaine Maxwell? 2 2015?
3 A...
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...alway@bbc.co.uk,
18 Jo-anne,pugh@bbc.co.uk,
19 dated 2 January 2015,
20 Bates No. GM_00068
21 3 Email from James Ball to Ross Gow, 30
22 dated 1 January 2015,
23 Bates No. RG(UK) 000002
24
25
DTI Court Reporting Solutions - New York...
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...Friday, January 30, 2015 2:04 PM
To: Martin G. Weinberg
Subject: Re: Fw: Fwd: Media Enquiry - The Guardian - Re: Jeffrey Epstein
From: David Pegg
Sent: Friday, January 30, 2015 12:00 PM
——EEEEa
To:
Subject: Fwd: Media Enquiry - The Guardian - Re: Jeffrey Epstein
Dear Mr Weinberg,
| hope this email...
Giuffre_Maxwell_Batch5_p00254.png
...Maxwell’s input into the content
of the January 2, 2015. And, again, nearly identical emails requesting input from Ms. Maxwell
based on media and media inquiries post-dating January 2, 2015, including press inquiries after
the filing of this lawsuit, were produced prior to the deposition and Plaintiff chose...
HOUSE_OVERSIGHT_026609.jpg
...Saturday, January 24 2015 05:22 AM
Subject: Fwd: January 23, 2015
From: jeffreyepsteinorg@gmail.com
To: Jeffrey Epstein ;
Avactrren te: photo_1(2).jog; photo2.jpg; photo2.jog; WP_20150123 005.jpg; 19th Century Medici Lions.png;
Florence.png
---------- Forwarded message ----------
—
Date: Fri, Jan 23, 2015...
Giuffre_Maxwell_Batch2_p00314.png
...Maxwell has no recollection of any non-privileged communication by which she specifically
authorized any agent or entity to “make statements on her behalf in January of 2015” nor does
she possess any documents beyond those already produced by which any such authorization may
be ascertained.
2. Identify any action...
HOUSE_OVERSIGHT_020419.jpg
267
CHAPTER TWENTY
The NSA’s Back Door
1. “You have private for-profit ...”--James Bamford and Tim De Chant, “Edward
Snowden on Cyber Warfare.” PBS Nova, January 8 2015
2. “Ames had been a...”—See Aldrich Ames, Appendix A
3. “All their classified information...”—Anonymous, “Out of Control,” NSA...
Giuffre_Maxwell_Batch7_p00102.png
...The Court should be aware that, in all three of Defendant’s various iterations of her
privilege log, there is no entry for any communication with Barden prior to January 10, 2015—a
week after Defendant issued the defamatory press release. See Composite Exhibit 2, Defendant’s
three privilege logs...
HOUSE_OVERSIGHT_024841.jpg
...587 15,000
2/1/2013 5,039 2/7/2015 12,370 10,000
1/10/2014 8,507 3/2/2015 12,430 f°
2/10/2014 9,642 3/20/2015 12,741 aad = = Sess 85358888
8/10/2014 11,694 7/7/2015 13,963 Fi...
Giuffre_Maxwell_Batch8_p00864.png
...The document states, it's Saturday
January 3, 2015. You issued your press
release on January 2, 2015.
Were you discussing with Prince
Andrew the subject of Virginia Roberts during
these calls?
MR. PAGLIUCA: Objection to the
form and foundation.
A. I don't know if I spoke to him...
DocumentCloud_Epstein_Docs_p00074.png
...Maxwell nor her agents approved or participated in any activity of any media
organization in its decision to publish or not to publish any part of the January 2015 statement.
EXHIBIT J ¥ 2; K ff 2-3.. Accordingly, “there is no basis for allowing the jury to consider [any]
article...
DocumentCloud_Epstein_Docs_p00073.png
...Maxwell and her agents had no responsibility for any media
organization’s decision to republish the January 2015 statement, and they did not participate in
any such decision. See EXHIBITS J § 24 & K {fj 2-3. Liability for republication by media
organizations of the January 2015 statement therefore is precluded...
DocumentCloud_Epstein_Docs_p01965.png
...At the direction of Barden, on January 2, 2015,
Gow sent to numerous representatives of British media
organizations an email containing “a quotable statement on
behalf of Maxwell” (the “Press Release”). The email was sent to
more than six and probably fewer than 30 media representatives.
It was not sent...
DocumentCloud_Epstein_Docs_p00799.png
...of the Memorandum contends the First Amendment bars liability for
republication by media organizations of the January 2015 statement. See Memo. of Law 16-17.
Argument IC. contends that under Geraci plaintiff is barred from introducing into evidence any
of the media organizations’ republication of the January 2015 statement. See...
DocumentCloud_Epstein_Docs_p00116.png
...Witness testimony and documentary evidence demonstrate the absence of substantial
truth to Plaintiff's claim that Maxwell assisted Epstein in converting her into what is commonly
referred to as a “sex slave.” The January 2015 statement’s denial of that claim cannot therefore
be defamatory.
4. The January 2015 statement...
Giuffre_Maxwell_Batch5_p00076.png
...January 3, 2015 Daily Mail article: “Harvard Law Professor Named Alongside
Prince Andrew in ‘Sex Slave’ Case Accuses Alleged Victim of ‘Making Up
Stories,’” attached hereto as Exhibit 22.
23. January 3, 2015 Press Statement issued by Ross Gow to Express set forth in
“Ghislaine Maxwell: I was not a...
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...See Exhibit 1, New York Daily News, April
7, 2015. Defendant has subjected Jane Doe No. 3 to horrific public attacks including publicly
calling her a “prostitute” and a “bad mother” to her three minor children. See Exhibit 2, Local 10
News, January 22, 2015.
Defendant has gone on a...
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Case 1:20-cr-00330-PAE Document 208-2 Filed 04/16/21 Page15of15
Case 9:08-cv-80736-KAM Document 280 Entered on FLSD Docket 01/02/2015 Page 14 of 14
CERTIFICATE OF SERVICE
I certify that the foregoing document was served on January 2, 2015, on the...
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Case 1:15-cv-07433-LAP Document 1330-22 Filed 01/05/24 Page 2 of 22
From: G Maxwell
Sent: Sunday, January 11, 2015 6:26 AM
To: JJep
Subject: Fw:
THE TERRAMAR PROJECT
FACEBOOK
TWITTER
G+
PINTEREST
INSTAGRAM
PLEDGE
THE DAILY CATCH
From: Philip Barden...
DocumentCloud_Epstein_Docs_p01089.png
...It was renewed, I believe on or around the
beginning of January 2015, potentially the 2nd of January
via email.
Q. Was the agreement revised when it was renewed?
A. It wasn't revised. It was a straightforward
re-establishment of the original agreement.
Q. Is it your belief that...
Giuffre_Maxwell_Batch6_p00286.png
...Gow and my client, on January 2, 2015, I prepared a further statement .. ., and
I instructed Mr. Gow to transmit it via email to” the journalists. Doc.542-7, Ex.K ¥ 10
(emphasis supplied). The answer also is found in Ms. Maxwell’s April 22, 2016,
testimony: “/M/y lawyer...
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...Ex.G at 31:2-36:4 & Depo. Exs.
3-4.
a. Reply: Plaintiff cites no contrary evidence and therefore the facts should be
deemed admitted.
18. Undisputed Fact 18: At Mr. Barden’s direction, on January 2, 2015, Mr. Gow sent
to numerous representatives of British media organizations an...
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